Entrepreneurs’ Telegram November 2025

Newsletter – 25.11.2025

Dear clients and partners,

In the latest edition of mailingLeitner Slovakia, we bring you a selection of the most important legislative changes effective from 2026, along with practical recommendations to help you navigate the new obligations and prepare for their impact.

We would like to draw your particular attention to the following topics:

Preparing for higher taxes and social security contributions as of 2026
Changes in transfer pricing
Tax amnesty: waiver of penalties and late-payment interest
Carbon Border Adjustment Mechanism: what changes in the new year
Limitation of input VAT deduction for cars also used for private purposes
E-invoicing

Higher taxes and social security contributions from 2026: what can be optimised in 2025

As of 2026, health insurance contribution rates will increase and new progressive personal income tax brackets will be introduced. In addition to the current 19% and 25% rates, new rates of 30% and 35% will apply to high-income individuals. From a tax planning perspective, it may therefore be beneficial to time bonuses and irregular income so that they are paid out no later than the end of 2025.

We would also like to highlight a potential overpayment of social insurance contributions where an employee receives income from several employers and exceeds the maximum assessment base. The Social Insurance Agency does not automatically refund such overpayments– a separate request must be filed. If the refund is obtained by 31 December 2025, it may result in lower health insurance contributions and a reduced tax burden.

Before the changes effective from 2026 become applicable, we therefore recommend preparing a clear tax and contribution plan and making key payments by the end of 2025 to mitigate cost impacts and protect employee net income.

Changes in transfer pricing

Significant changes are ahead in the area of transfer pricing. As of the 2025 tax period, taxpayers who previously prepared simplified transfer pricing documentation will face a new compliance approach. These taxpayers will be able to meet their obligation by completing Table I – Transactions with related parties directly in the corporate income tax return. However, if Table I is incomplete or inaccurate, the taxpayer will be required to prepare simplified transfer pricing documentation (which itself remains unchanged).

In connection with this change, the corporate income tax return form is being amended. The expanded Table I will require much more detailed reporting of individual related-party transactions, including the transaction type codes, the name of the related party and its country of residence.

Tax amnesty

A new regulation effective from 1 October 2025 will allow for the waiver of penalties and late-payment interest where taxpayers subsequently comply with their obligations. The amnesty will apply to taxpayers with tax arrears recorded as of 30 September 2025 (inclusive), provided that between 1 January 2026 and 30 June 2026 they pay the outstanding tax and/or file an ordinary or supplementary tax return. The amnesty will apply to income tax, VAT, excise duties, financial transaction tax, motor vehicle tax, insurance tax and the tax on sweetened beverages.

In view of the above, we recommend that entrepreneurs consider a tax review aimed at identifying any arrears, errors or incomplete filings for prior years and remedying them through an ordinary or supplementary tax return. This may help take advantage of the amnesty before it expires and at the same time reduce the risk of future sanctions – particularly in cases where transfer prices have not been set correctly. In this area, penalties are especially high (20% p.a.) and the statute of limitation period is long (up to 10 years).

New rules for the Carbon Border Adjustment Mechanism (CBAM)

As of 1 January 2026, the transitional period for CBAM will end and the permanent system will be launched. Quarterly reporting will be replaced by a single annual CBAM report, required only if annual imports exceed 50 tons (excluding electricity and hydrogen). A de minimis exemption will apply to smaller importers – where annual volumes do not exceed 50 tons, no reporting obligation will arise.

Companies expecting to exceed this threshold in 2026 must apply for authorized CBAM declarant status by the end of 2025 and subsequently submit their first annual CBAM report for 2026.

As of 2027, importers will be required to purchase CBAM certificates based on the embedded emissions in their imports. Throughout the year, they must hold a sufficient number of certificates – at least 50% of the cumulative embedded emissions for the year. The annual report and the certificate surrender will be due by 30 September 2027.

Limitation of input VAT deduction for cars used also for private purposes

In connection with the upcoming changes to VAT deduction rules for cars (Company Cars – What Changes from 2026? – LeitnerLeitner Slovakia), we recommend that businesses assess the new obligations applicable from January 2026, consider purchasing a vehicle by the end of 2025, or evaluate whether purchasing or leasing is more advantageous in their specific situation.

Mandatory e-invoicing and data reporting

Slovakia plans to introduce mandatory real-time e-invoicing in a structured format. Invoice data will be transmitted automatically to the tax authorities. The planned implementation of e-invoicing in Slovakia is as follows:

As of 1 January 2027 – mandatory real time e-invoicing for local (B2B and B2G) supplies between VAT payers established in Slovakia
As of 1 July 2030:
- Mandatory real time e-invoicing for all VAT-payers registered in Slovakia for local (B2B and B2G) and cross-border EU supplies
- Cancellation of the obligation to submit control statements and EC sales lists

The amendment is expected to be approved by the end of 2025. We recommend closely monitoring the legislative process, as these substantial changes will require new IT solutions as well as adjustments to internal processes.

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